BIOPESTICIDES REGISTRATION ACTION DOCUMENT

Oregano Oil

(Origanum vulgar)

PC Code 004300

U.S. Environmental Protection Agency

Office of Pesticide Programs

Biopesticides and Pollution Prevention Division

(last updated June 10, 2011)

This document is for informational purposes only and is representative of the Agency’s 

justification in registering products containing this active ingredient. This is not a legal 

document.
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Biopesticides Registration Action Document

TABLE OF CONTENTS

I. EXECUTIVE SUMMARY...................................................................................................... 4

II. ACTIVE INGREDIENT OVERVIEW ................................................................................ 5

III. REGULATORY BACKGROUND...................................................................................... 5

A. Applications for Pesticide Registration..................................................................... 5

B. Food Tolerance Exemptions....................................................................................... 5

IV. RISK ASSESSMENT............................................................................................................ 5

A. Product Chemistry Assessment (40 CFR § 158.2030) ............................................. 5

B. Human Health Assessment (40 CFR § 158.2050)..................................................... 5

C. Environmental Assessment (40 CFR § 158.2060) .................................................... 8

V. RISK MANAGEMENT DECISION..................................................................................... 9

A. Determination of Eligibility for Registration ........................................................... 9

B. Regulatory Decision .................................................................................................... 9

VI. ENVIRONMENTAL JUSTICE........................................................................................... 9

V1I. ACTIONS REQUIRED BY REGISTRANTS.................................................................. 9

A. Reporting of Adverse Effects................................................................................... 10

B. Reporting of Hypersensitivity Incidents ................................................................. 10

APPENDIX A. DATA REQUIREMENTS (40 CFR PART 158—SUBPART U) ............... 11

REFERENCES.............................................................................................................................14
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Biopesticides Registration Action Document

Science Reviews

Sadaf Shaukat

Russell Jones, Ph.D.

Regulations

Linda A. Hollis, M.S . Chief, Biochemical Pesticides Branch

Leonard S. Cole, Jr., M.S. Senior Regulatory Action Leader
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I. EXECUTIVE SUMMARY

Oregano Oil is derived from a common species of Origanum, a genus of the mint family

(Lamiaceae). Oregano Oil is also considered an antioxidant with properties that assist in the 

inhibition of bacterial growth and inhibiting the growth of fungi. Oregano Oil is most commonly 

found in Turkey. Oregano Oil is also used for the treatment of several diseases, including 

diabetes mellitus. In summary, Oregano Oil is a multi-purpose oil with uses that span cooking to 

general health. 

The Biopesticides and Pollution Prevention Division (BPPD) determined that the 

data/information submitted for Tier I Acute Toxicity and Product Chemistry for Oregano Oil 

adequately satisfy current guideline requirements (refer to 40 CFR Subpart U § 158.2000).

Nontarget toxicology data requirements were satisfied by the submission of data waivers for 

nontarget organism that were granted by BPPD based on the information submitted by the 

applicant. The submitted information demonstrated no hazards to nontarget species as presented 

in the scientific literature and rationale for the proposed use of Oregano Oil as a biochemical 

fungicide. Based on the information discussed above, the Agency determined that Oregano Oil

as an active ingredient will have No Adverse Effects (NAE) on threatened and/or endangered 

species. 

Based on the Acute Toxicity and Product Chemistry data available to the Agency, the active 

ingredient is classified into Toxicity Category III for oral toxicity and Toxicity Category IV for 

primary eye irritation, acute dermal, acute inhalation, and skin irritation. The Agency 

determined that no unreasonable adverse effects to the U.S. population will result from the use of 

the active ingredient when used as directed by the label. There are no reports of adverse effects 

following regular human exposure and consumption of Oregano Oil. Moreover, the pesticidal 

usage of this biochemical will not have any harmful environmental effects.

The Biopesticides and Pollution Prevention Division (BPPD) reviewed data/information in 

support of the requirements for granting registration under Section 3(c)(5) of the Federal 

Insecticide, Fungicide and Rodenticide Act (FIFRA). Based on data available, BPPD

determined that the data/information submitted adequately satisfy current guideline requirements 

(please refer to 40 CFR Subpart U § 158.2000). 

On October 1, 2009, the Agency announced a policy to provide a more meaningful opportunity 

for the public to participate in major registration decisions before they occur. According to this 

policy, the Agency intends to provide a public comment period prior to making a registration 

decision for, at minimum, the following types of applications: new active ingredients; first food 

uses; first outdoor uses; first residential uses; and any registration decisions for which the 

Agency believes there may be substantial public interest.

Consistent with the policy of making registration actions more transparent, Oregano Oil was

subject to a 30-day comment period because it is a new active ingredient. During this comment 

period, no comments were received on the Agency’s preliminary decision to register Oregano 

Oil. Therefore, the Agency maintained that, based upon the risk assessment and information 

submitted in support of registration of Oregano Oil, it was in the best interest of the public and 
Oregano Oil (Origanum vulgar) Page 5 of 19

Biopesticides Registration Action Document

the environment to issue the registration of this pesticide. The basis for this decision can be 

found in the risk assessment for Oregano Oil, which is characterized throughout this BRAD. 

II. ACTIVE INGREDIENT OVERVIEW

Biological Name: Oregano Oil (from Origanum vulgar) 

OPP Chemical Code: 004300

Type of Pesticide: Biochemical Pesticide/Biofungicide

III. REGULATORY BACKGROUND

A. Applications for Pesticide Registration

On August 18, 2007, Gary Libman of GNL Consultation Services (39 Sage Hill Drive, Placitas, 

New Mexico 87043), acting as the authorized agent for Moss Buster LLC, (address: 3002 Fair 

Lane, Mason City, Iowa 50401), submitted an application to register Oregano Oil (EPA File 

Symbol 84316-R) under section 3 of the Federal Insecticide, Fungicide, and Rodenticide Act 

(FIFRA). On February 27, 2008, the Agency announced receipt of this application to register a 

pesticide product containing a new active ingredient (73 Federal Register [FR] 10435) and 

opened a 30-day public comment period pursuant to the provisions of FIFRA section 3(c)(4). No 

comments were received following this publication. 

B. Food Tolerance Exemptions

Currently, this active ingredient is not proposed for food or feed uses.

IV. RISK ASSESSMENT

A. Product Chemistry Assessment (40 CFR § 158.2030)

All product chemistry data requirements for Oregano Oil are satisfied. The applicant must 

submit the results of one year storage stability and corrosion characteristics studies for the end 

use product twelve months post registration. These guideline study requirements are OCSPP 

830.6317, 830.6320). 

B. Human Health Assessment (40 CFR § 158.2050)

1. Toxicity

All toxicology data requirements for Oregano Oil are satisfied. Acceptable Tier I mammalian 

toxicology data/information support the registration of Oregano Oil. Furthermore, Tier II and 

Tier III studies were not required for Oregano Oil based on the lack of acute toxicity in the Tier I 

studies. 
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For acute toxicity data requirements, toxicity categories are assigned based on the hazard(s) 

identified from studies and/or information on file with the Agency. The active ingredient is 

classified into Toxicity Category I, II, III or IV where Toxicity Category I indicates the highest 

toxicity and Toxicity Category IV indicates the lowest toxicity. For more information, refer 

http://www.epa.gov/pesticides/pestlabels/. 

Oregano Oil is classified into category III for oral toxicity, and IV for primary eye irritation,

dermal, inhalation and skin irritation. 

Adequate mammalian toxicology data/information is available to support registration of Oregano 

Oil. All toxicology data requirements for Oregano Oil are satisfied. 

a. Acute Toxicity 

Acute toxicity studies/information submitted in support of the active ingredient, Oregano 

Oil are adequate for registration of this active ingredient. Based on the review and 

analysis of the information, guideline studies, and submitted literature discussed in this 

section of the BRAD, no additional toxicity data are required to support the nonfood use 

of this active ingredient. 

b. Subchronic Toxicity 

Tier I information did not trigger subchronic toxicity data.

c. Developmental Toxicity and Mutagenicity

These data were not required because Oregano Oil is being used on roof tops, golf 

greens, and landscape timbers; therefore, it is not expected to result in significant 

exposure to human females. 

d. Effects on the Endocrine System 

EPA is required under the Federal Food, Drug, and Cosmetic Act (FFDCA), as amended 

by the Food Quality Protection Act (FQPA), to develop a screening program to determine 

whether certain substances (including all pesticide active and other ingredients) “may 

have an effect in humans that is similar to an effect produced by a naturally occurring 

estrogen, or other such endocrine effects as the Administrator may designate.” Following 

the recommendations of its Endocrine Disruptor Screening and Testing Advisory 

Committee (EDSTAC), EPA determined that there was scientific basis for including, as 

part of the program, the androgen and thyroid hormone systems, in addition to the 

estrogen hormone system. EPA also adopted EDSTAC’s recommendation that the 

program include evaluations of potential effects in wildlife. For pesticide chemicals, the 

Agency will use FIFRA and, to the extent that effects in wildlife may help determine 

whether a substance may have an effect in humans, FFDCA authority to require the 

wildlife evaluations. As the science develops and resources allow, screening of 
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Biopesticides Registration Action Document

additional hormone systems may be added to the Endocrine Disruptor Screening Program 

(EDSP). 

The Agency is not requiring information on the endocrine effects of Oregano Oil at this 

time. The Agency has considered, among other relevant factors, available information 

concerning whether the active ingredient may have an effect on humans similar to an 

effect produced by naturally occurring estrogen or other endocrine effects. There is no 

known metabolite that acts as an endocrine disrupter produced by this active ingredient. 

Based on the low potential exposure level associated with the proposed use of the end use 

products, the Agency expects no incremental adverse effects to the endocrine or immune 

systems. 

2. Dose Response Assessment 

No toxicological endpoints were identified; therefore, a dose response assessment was not 

required. 

3. Drinking Water Exposure and Risk Characterization 

No significant exposure via drinking water is expected when Oregano Oil is used according to 

the product label directions. The active ingredient is not to be applied directly to water or to 

areas where surface water is present, and if used as labeled, is not likely to accumulate in 

drinking water. In the unlikely event that exposure via drinking water did occur, the health risk 

would be expected to be minimal, based on the low acute oral toxicity of Oregano Oil. 

4. Occupational, Residential, School and Day Care Exposure and Risk 

Characterization Occupational Exposure and Risk Characterization 

No occupational estimates are made in this assessment.

5. Residential, School and Day Care Exposure and Risk Characterization

Oregano Oil is considered ubiquitous in nature, and it is widely used in food; therefore, no risk 

characterization was done for incidental oral scenarios. Should accidental exposure occur, the 

health risk is expected to be minimal, based on the low acute oral, dermal, and inhalation toxicity 

of Oregano Oil. 

6. Aggregate Exposure from Multiple Routes Including Dermal, Oral, 

and Inhalation 

There is a reasonable certainty that no harm to the US population will result from aggregate 

exposure to Oregano Oil. The Agency arrived at this conclusion based on the low level of 

toxicity of Oregano Oil. Further, Oregano Oil is a food ingredient consumed by the general 

public without any reported adverse effects on human health. 
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7. Cumulative Effects 

Based on the information available to the Agency, there is no indication that toxic effects 

associated with exposure to Oregano Oil are of toxicological concern. Because of the active 

ingredient’s low toxicity, cumulative effects with other substances that share a common 

mechanism of toxicity are not expected. 

8. Risk Characterization 

The Agency considered human exposure to Oregano Oil in light of the relevant safety factors in 

FQPA and FIFRA. A determination was made that no unreasonable adverse effects to the U.S. 

population in general, and to infants and children in particular, will result from the use of 

Oregano Oil when used in accordance with label instructions.

C. Environmental Assessment (40 CFR § 158.2060)

1. Ecological Hazards 

Ecological effects data requirements for Oregano Oil were satisfied by the submission of data 

waiver requests/data pertaining to effects on nontarget organisms. Based on the waiver rationale, 

the Agency concluded that exposure and risk from the proposed use of Oregano Oil is not 

expected to occur or pose a threat to nontarget organisms, including plants. Oregano Oil was 

deemed to be practically nontoxic to honeybees with an LC50 of 331.3 μg/bee as shown in Table 

3 below.

2. Environmental Fate and Ground Water Data 

The need for environmental fate and groundwater data was not triggered because Oregano Oil 

acute toxicity studies did not trigger any additional Tier I studies. 

3. Ecological Exposure and Risk Characterization 

Based on the information submitted in the data waiver requests for nontarget plants and data for 

nontarget insects, exposure and risk from the proposed use of Oregano Oil is not expected to 

occur for other nontarget organisms. 

4. Endangered Species Assessment 

Based on the information discussed above, the Agency determined that registered use of Oregano 

Oil as an active ingredient will have No Adverse Effects (NAE) on threatened and/or 

endangered species. When the product is used according to label use directions, there are no 

concerns for any nontarget organisms. 
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V. Risk Management Decision

A. Determination of Eligibility for Registration

Section 3(c)(5) of FIFRA provides for the registration of a new active ingredient if it is 

determined that (A) its composition is such as to warrant the proposed claims for it; (B) its 

labeling and other materials required to be submitted comply with the requirements of FIFRA; 

(C) it will perform its intended function without unreasonable adverse effects on the 

environment; and (D) when used in accordance with widespread and commonly recognized 

practice it will not generally cause unreasonable adverse effects on the environment. The four 

criteria of the Eligibility Determination for Pesticidal Active Ingredients are satisfied by the 

science assessments supporting products containing Oregano Oil. Such products are not 

expected to cause unreasonable adverse effects, and are likely to provide protection as claimed 

when used according to label instructions. Therefore, Oregano Oil is registered for the labeled 

uses. 

B. Regulatory Decision

As set forth above, EPA determined that Oregano Oil presents no issues of toxicological, 

ecological, or environmental concern. Accordingly, EPA granted a registration for Oregano Oil 

under the provisions of FIFRA § 3(c)(5) for use as a biochemical fungicide. 

Conditional/Unconditional Registration 

All data requirements are fulfilled, and EPA determined that unconditional registration of 

Oregano Oil is appropriate. 

VI. ENVIRONMENTAL JUSTICE 

EPA seeks to achieve environmental justice, the fair treatment and meaningful involvement of all 

people, regardless of race, color, national origin, or income, in the development, implementation, 

and enforcement of environmental laws, regulations, and policies. To help address potential 

environmental justice issues, the Agency seeks information on any groups or segments of the 

population who, as a result of their location, cultural practices, or other factors, may have 

atypical, unusually high exposure to Oregano Oil compared to the general population. 

V1I. ACTIONS REQUIRED BY REGISTRANTS

The Agency evaluated all of the data submitted in connection with the initial registration of 

Oregano Oil and determined that these data are sufficient to satisfy current registration data 

requirements. For new uses and/or changes to existing uses, additional data may be required. 
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Notwithstanding the information stated in the previous paragraph, it should be clearly understood 

that certain, specific, data are required to be reported to the Agency as a requirement for 

maintaining the Federal registration for a pesticide product. In addition, the applicant must 

submit the results of one year storage stability and corrosion characteristics studies for the end 

use product twelve months post registration. A brief summary of these types of data are listed 

below. 

A. Reporting of Adverse Effects

Reports of all incidents of adverse effects to the environment must be submitted to the Agency 

under the provisions of Section 6(a)(2) of the Federal Insecticide, Fungicide and Rodenticide 

Act. 

B. Reporting of Hypersensitivity Incidents

All incidents of hypersensitivity (including both suspected and confirmed incidents) must be 

reported to the Agency under the provisions of 40 CFR Part 158.2050 (d).
Appendix A. Data Requirements (40 CFR Part 158—Subpart U)

*NOTE: MRID numbers listed in the following tables are representative of supporting data for 

the original registration of the product containing this active ingredient. Subsequent to this 

registration, there may be additional MRIDs that support registration of other products 

containing this active ingredient.

TABLE 1. Product Chemistry Data Requirements for Oregano Oil (40 CFR § 158.2030) 

OPPTS 

Guideline No. Study Results (below are example results)

830.1550 to 

830.1670 

Product identity; 

Manufacturing process; 

Discussion of formation of unintentional 

ingredients 

Submitted data satisfy the requirements for product identity, 

manufacturing process, and discussion of formation of 

impurities. 

830.1700 Analysis of samples Submitted data satisfy the requirements for analysis of 

samples. 

830.1750 Certification of limits Limits listed in the CSF are adequate / acceptable. 

830.1800 Analytical method Acceptable. 

TABLE 2. Physical and Chemical Properties of Oregano Oil (40 CFR § 158.2030) 

OPPTS 

Guideline No. Property Description of Result

830.6302 Color Yellow @ 21oC 

830.6303 Physical State Liquid @ 21oC 

830.6304 Odor Minty 

830.6313 Stability to Normal and Elevated 

Temperatures, Metals and Metal Ions 

Stable at room and elevated temperatures and in the presence 

of metals and ions. 

830.6314 Oxidation/Reduction: 

Chemical Incompatibility 

Dihydronepetalactone was relatively stable in solution with 

metals and metal salts after 14 days at 25oC, with slight 

decreases at 54oC after 14 days. 

830.6315 Flammability >99oC 

830.6317 Storage Stability In short-term testing at 25 and 54oC, dihydronepetalactone 

content was relatively stable. Guideline study is in progress. 

830.6319 Miscibility Not applicable, product is not to be diluted in petroleum 

solvents 

830.6320 Corrosion Characteristics Guideline study is in progress 

830.7000 pH 3.97 @ 25oC (1% w/w in deionized water) 

830.7050 UV/Visible Light Absorption Not applicable 

830.7100 Viscosity 18.09 mm2/s (cSt) @ 22oC 

830.7200 Melting Point/Range Not applicable, product is a liquid 

830.7220 Boiling Point/Range 266.0 ± 12.0oC 

830.7300 Density 1.0334 @ 20.7oC 
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Biopesticides Registration Action Document

OPPTS 

Guideline No. Property Description of Result

830.7520 Particle Size, Fiber Length and Diameter 

Distribution 

830.7550 

830.7560 

830.7570 

Partition Coefficient (nOctanol/Water) 

Not applicable, required only for pure active ingredient 

830.7840 Water Solubility 0.254 ± 0.013 g/L @ 30oC 

830.7950 Vapor Pressure 591, 707, 907. 1100, 1320, and 1630 Pa @ 20, 25, 30, 35, and 40oC, 

respectively 

TABLE 3. Human Toxicology Data Requirements for Refined Oil of Refined Oil of Oregano 

Oil (40 CFR § 158.2050)

Study/OPPTS Guideline No. Results Toxicity 

Category/Description

Acute oral toxicity (rat) 

(870.1100) 

LD50 = 1750 (95% C.L.455.5-9230) mg/kg (females 

using the Up-and Down Method) 

III / MRID 46977401 

Acute dermal toxicity (rat) 

(870.1200) 

LD50 > 5000 mg/kg for males, females, and for both 

sexes combined. 

IV / MRID 46977402 

Acute inhalation toxicity (rat) 

(870.1300) 

LC50 > 5.5 mg/L (males, females, and both sexes 

combined; 4 hour nose-only exposure) 

IV / MRID 46977406 

Primary eye irritation (rabbit) 

(870.2400) 

Corneal opacity persisted for 24 to 48 hours after 

treatment with clearance by 72 hours. Iritis was noted at 

1 and 24 hours after treatment and cleared by the 48 

hour observation. Conjunctival irritation was noted on 

one rabbit one hour throughout 48 hours after treatment 

with clearance by 72 hours. The maximum average 

score was 24.0 at 24 hours after test material instillation. 

Hydrogenated Catmint Oil was mildly irritating. 

III / MRID 46977403 

Primary dermal irritation (rabbit) 

(870.2500) 

No dermal irritation or clinical signs of toxicity were 

observed during the study. The primary irritation index 

was 0.0. 

IV / MRID 46977404 

Dermal sensitization (mouse) 

(870.2600) 

A local lymph node assay (LLNA) indicated that 

hydrogenated catmint oil is not a dermal sensitizer. 

--- / MRID 46977405 

90-Day oral toxicity (rat) 

(870.3100) 

Minimal to mild degeneration / regeneration of the 

olfactory epithelium lining the nasal turbinates of males 

and females. 

NOAEL = 200 mg/kg 

LOAEL = 1000 mg/kg 

MRID 46977407 

90-Day dermal toxicity (rat) 

(870.3250) 

No adverse effects were reported. 

NOAEL = 1000 mg/kg 

LOAEL > 1000 mg/kg 

MRID 46977415 

Mutagenicity (Bateria) 

(870.5100, 5300 and 5375) 

Negative 

Doses tested:0 to 5000 μg/plate with or without 

metabolic activation (S9 mix) 

MRID 46977410 
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Biopesticides Registration Action Document

Study/OPPTS Guideline No. Results Toxicity 

Category/Description

Developmental toxicity (rat) 

(870.3700) 

No adverse effects were reported. 

NOAEL = 1000 mg/kg 

LOAEL > 1000 mg/kg 

MRID 46977408 

TABLE 4. Nontarget Organism Toxicity Requirements for Oregano Oil (40 CFR § 158.2060) 

Study/OPPTS Guideline No. Results

Avian acute oral toxicity 

Colinus virginianus

(850.2100) 

Data Waiver Request submitted 

Avian dietary toxicity 

Colinus virginianus 

(850.2200) 

Data Waiver Request submitted 

Avian dietary toxicity 

Anas platyrhynchos 

(850.2200) 

Data Waiver Request submitted 

Aquatic invertebrate acute toxicity 

(Daphnia magna) 

(850.1010) 

Data Waiver Request submitted 

Freshwater fish LC50 

(Oncorhynchus mykiss) 

(850.1075) 

Data Waiver Request submitted 

Non-target plant studies 

(850.4000-4800, as applicable) 

Data Waiver Request submitted 

Non-target insect testing 

(880.4350) 

Data Waiver Request submitted 

Non-Target Toxicity

Table 5. Nontarget Organism Assessment

Study Type/OPPTS Guideline LD50 or LC50 Results Toxicity Category MRID

Seedling Emergence (Guideline 850.4100)

Vegetative Vigor (Guideline 850.4150)

Information/rationale 

submitted to address data 

requirement

Acceptable N/A
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REFERENCES

48322103 Libman, G. (2010) Physical and Chemical Characteristics of the TGAI: (Moss 

Buster). Unpublished study prepared by GNL Consultation Services. 5 p.

48322104 Libman, G. (2010) Physical and Chemical Properties Information on Oregano Oil: 

(Moss Buster). Unpublished study prepared by GNL Consultation Services. 5 p.

48322101 Libman, G. (2010) Product Chemistry Test Guidelines: (Moss Buster). Unpublished 

study prepared by GNL Consultation Services. 7 p.

48322101 Libman, G. (2010) Product Chemistry Test Guidelines: (Moss Buster). Unpublished 

study prepared by GNL Consultation Services. 7 p.

48322104 Libman, G. (2010) Physical and Chemical Properties Information on Oregano Oil: 

(Moss Buster). Unpublished study prepared by GNL Consultation Services. 5 p.

48322104 Libman, G. (2010) Physical and Chemical Properties Information on Oregano Oil: 

(Moss Buster). Unpublished study prepared by GNL Consultation Services. 5 p.

48322101 Libman, G. (2010) Product Chemistry Test Guidelines: (Moss Buster). Unpublished 

study prepared by GNL Consultation Services. 7 p.

48322104 Libman, G. (2010) Physical and Chemical Properties Information on Oregano Oil: 

(Moss Buster). Unpublished study prepared by GNL Consultation Services. 5 p.

48322104 Libman, G. (2010) Physical and Chemical Properties Information on Oregano Oil: 

(Moss Buster). Unpublished study prepared by GNL Consultation Services. 5 p.

48322104 Libman, G. (2010) Physical and Chemical Properties Information on Oregano Oil: 

(Moss Buster). Unpublished study prepared by GNL Consultation Services. 5 p.

47557101 Libman, G. (2008) Waiver Request for Biochemical Pesticide Data Requirements: 

Moss Buster. Unpublished study prepared by GNL Consultation Services. 44 p.

48093901 Libman, G. (2010) Waiver Request for Biochemical Pesticide Data Requirements. 

Unpublished Study Prepared by GNL Consultation Services. 49 p.

47557101 Libman, G. (2008) Waiver Request for Biochemical Pesticide Data Requirements: 

Moss Buster. Unpublished study prepared by GNL Consultation Services. 44 p.

48093901 Libman, G. (2010) Waiver Request for Biochemical Pesticide Data Requirements. 

Unpublished Study Prepared by GNL Consultation Services. 49 p.

47557101 Libman, G. (2008) Waiver Request for Biochemical Pesticide Data Requirements: 

Moss Buster. Unpublished study prepared by GNL Consultation Services. 44 p.

48093901 Libman, G. (2010) Waiver Request for Biochemical Pesticide Data Requirements. 

Unpublished Study Prepared by GNL Consultation Services. 49 p.

47557101 Libman, G. (2008) Waiver Request for Biochemical Pesticide Data Requirements: 

Moss Buster. Unpublished study prepared by GNL Consultation Services. 44 p.
Oregano Oil (Origanum vulgar) Page 15 of 19

Biopesticides Registration Action Document

48093901 Libman, G. (2010) Waiver Request for Biochemical Pesticide Data Requirements. 

Unpublished Study Prepared by GNL Consultation Services. 49 p.

47557101 Libman, G. (2008) Waiver Request for Biochemical Pesticide Data Requirements: 

Moss Buster. Unpublished study prepared by GNL Consultation Services. 44 p.

48093901 Libman, G. (2010) Waiver Request for Biochemical Pesticide Data Requirements. 

Unpublished Study Prepared by GNL Consultation Services. 49 p.

47557101 Libman, G. (2008) Waiver Request for Biochemical Pesticide Data Requirements: 

Moss Buster. Unpublished study prepared by GNL Consultation Services. 44 p.

48093901 Libman, G. (2010) Waiver Request for Biochemical Pesticide Data Requirements. 

Unpublished Study Prepared by GNL Consultation Services. 49 p.

47557101 Libman, G. (2008) Waiver Request for Biochemical Pesticide Data Requirements: 

Moss Buster. Unpublished study prepared by GNL Consultation Services. 44 p.

48093901 Libman, G. (2010) Waiver Request for Biochemical Pesticide Data Requirements.

Unpublished Study Prepared by GNL Consultation Services. 49 p.

47557101 Libman, G. (2008) Waiver Request for Biochemical Pesticide Data Requirements: 

Moss Buster. Unpublished study prepared by GNL Consultation Services. 44 p.

48093901 Libman, G. (2010) Waiver Request for Biochemical Pesticide Data Requirements. 

Unpublished Study Prepared by GNL Consultation Services. 49 p.

48093901 Libman, G. (2010) Waiver Request for Biochemical Pesticide Data Requirements. 

Unpublished Study Prepared by GNL Consultation Services. 49 p.

48363101 Libman, G. (2010) Waiver Request for Biochemical Pesticide Data Requirements 

NonTarget Plants: Moss Buster. Unpublished study prepared by GNL Consultation 

Services. 8 p.

47557101 Libman, G. (2008) Waiver Request for Biochemical Pesticide Data Requirements: 

Moss Buster. Unpublished study prepared by GNL Consultation Services. 44 p.

48093901 Libman, G. (2010) Waiver Request for Biochemical Pesticide Data Requirements. 

Unpublished Study Prepared by GNL Consultation Services. 49 p.

48363101 Libman, G. (2010) Waiver Request for Biochemical Pesticide Data Requirements 

NonTarget Plants: Moss Buster. Unpublished study prepared by GNL Consultation 

Services. 8 p.

47557101 Libman, G. (2008) Waiver Request for Biochemical Pesticide Data Requirements: 

Moss Buster. Unpublished study prepared by GNL Consultation Services. 44 p.

48093901 Libman, G. (2010) Waiver Request for Biochemical Pesticide Data Requirements. 

Unpublished Study Prepared by GNL Consultation Services. 49 p.

48363101 Libman, G. (2010) Waiver Request for Biochemical Pesticide Data Requirements 

NonTarget Plants: Moss Buster. Unpublished study prepared by GNL Consultation 

Services. 8 p.
Oregano Oil (Origanum vulgar) Page 16 of 19

Biopesticides Registration Action Document

47557101 Libman, G. (2008) Waiver Request for Biochemical Pesticide Data Requirements: 

Moss Buster. Unpublished study prepared by GNL Consultation Services. 44 p.

48363101 Libman, G. (2010) Waiver Request for Biochemical Pesticide Data Requirements 

NonTarget Plants: Moss Buster. Unpublished study prepared by GNL Consultation 

Services. 8 p.

47557101 Libman, G. (2008) Waiver Request for Biochemical Pesticide Data Requirements: 

Moss Buster. Unpublished study prepared by GNL Consultation Services. 44 p.

48093901 Libman, G. (2010) Waiver Request for Biochemical Pesticide Data Requirements. 

Unpublished Study Prepared by GNL Consultation Services. 49 p.

48363101 Libman, G. (2010) Waiver Request for Biochemical Pesticide Data Requirements 

NonTarget Plants: Moss Buster. Unpublished study prepared by GNL Consultation 

Services. 8 p.

47557101 Libman, G. (2008) Waiver Request for Biochemical Pesticide Data Requirements: 

Moss Buster. Unpublished study prepared by GNL Consultation Services. 44 p.

48093901 Libman, G. (2010) Waiver Request for Biochemical Pesticide Data Requirements. 

Unpublished Study Prepared by GNL Consultation Services. 49 p.

48363101 Libman, G. (2010) Waiver Request for Biochemical Pesticide Data Requirements 

NonTarget Plants: Moss Buster. Unpublished study prepared by GNL Consultation 

Services. 8 p.

48093901 Libman, G. (2010) Waiver Request for Biochemical Pesticide Data Requirements. 

Unpublished Study Prepared by GNL Consultation Services. 49 p.

47276801 Libman, G. (2007) Waiver Request for Biochemical Pesticide Data Requirements: 

Moss Busters. Unpublished study prepared by GNL Consultation Services. 36 p.

47557101 Libman, G. (2008) Waiver Request for Biochemical Pesticide Data Requirements: 

Moss Buster. Unpublished study prepared by GNL Consultation Services. 44 p.

48093901 Libman, G. (2010) Waiver Request for Biochemical Pesticide Data Requirements. 

Unpublished Study Prepared by GNL Consultation Services. 49 p.

47276801 Libman, G. (2007) Waiver Request for Biochemical Pesticide Data Requirements: 

Moss Busters. Unpublished study prepared by GNL Consultation Services. 36 p.

47557101 Libman, G. (2008) Waiver Request for Biochemical Pesticide Data Requirements: 

Moss Buster. Unpublished study prepared by GNL Consultation Services. 44 p.

48093901 Libman, G. (2010) Waiver Request for Biochemical Pesticide Data Requirements. 

Unpublished Study Prepared by GNL Consultation Services. 49 p.

47276801 Libman, G. (2007) Waiver Request for Biochemical Pesticide Data Requirements: 

Moss Busters. Unpublished study prepared by GNL Consultation Services. 36 p.
Oregano Oil (Origanum vulgar) Page 17 of 19

Biopesticides Registration Action Document

47557101 Libman, G. (2008) Waiver Request for Biochemical Pesticide Data Requirements: 

Moss Buster. Unpublished study prepared by GNL Consultation Services. 44 p.

48093901 Libman, G. (2010) Waiver Request for Biochemical Pesticide Data Requirements. 

Unpublished Study Prepared by GNL Consultation Services. 49 p.

47247401 Lowe, C. (2007) Primary Eye Irritation Study in Rabbits: Moss Buster. Project 

Number: 22491, P324. Unpublished study prepared by Product Safety Laboratories. 

17 p.

47276801 Libman, G. (2007) Waiver Request for Biochemical Pesticide Data Requirements: 

Moss Busters. Unpublished study prepared by GNL Consultation Services. 36 p.

47557101 Libman, G. (2008) Waiver Request for Biochemical Pesticide Data Requirements: 

Moss Buster. Unpublished study prepared by GNL Consultation Services. 44 p.

48093901 Libman, G. (2010) Waiver Request for Biochemical Pesticide Data Requirements. 

Unpublished Study Prepared by GNL Consultation Services. 49 p.

47276801 Libman, G. (2007) Waiver Request for Biochemical Pesticide Data Requirements: 

Moss Busters. Unpublished study prepared by GNL Consultation Services. 36 p.

47557101 Libman, G. (2008) Waiver Request for Biochemical Pesticide Data Requirements: 

Moss Buster. Unpublished study prepared by GNL Consultation Services. 44 p.

48093901 Libman, G. (2010) Waiver Request for Biochemical Pesticide Data Requirements. 

Unpublished Study Prepared by GNL Consultation Services. 49 p.

47276801 Libman, G. (2007) Waiver Request for Biochemical Pesticide Data Requirements: 

Moss Busters. Unpublished study prepared by GNL Consultation Services. 36 p.

48093901 Libman, G. (2010) Waiver Request for Biochemical Pesticide Data Requirements. 

Unpublished Study Prepared by GNL Consultation Services. 49 p.

47276801 Libman, G. (2007) Waiver Request for Biochemical Pesticide Data Requirements: 

Moss Busters. Unpublished study prepared by GNL Consultation Services. 36 p.

48093901 Libman, G. (2010) Waiver Request for Biochemical Pesticide Data Requirements. 

Unpublished Study Prepared by GNL Consultation Services. 49 p.

47276801 Libman, G. (2007) Waiver Request for Biochemical Pesticide Data Requirements: 

Moss Busters. Unpublished study prepared by GNL Consultation Services. 36 p.

47557101 Libman, G. (2008) Waiver Request for Biochemical Pesticide Data Requirements: 

Moss Buster. Unpublished study prepared by GNL Consultation Services. 44 p.

48093901 Libman, G. (2010) Waiver Request for Biochemical Pesticide Data Requirements. 

Unpublished Study Prepared by GNL Consultation Services. 49 p.

47557101 Libman, G. (2008) Waiver Request for Biochemical Pesticide Data Requirements: 
Oregano Oil (Origanum vulgar) Page 18 of 19

Biopesticides Registration Action Document

Moss Buster. Unpublished study prepared by GNL Consultation Services. 44 p.

48093901 Libman, G. (2010) Waiver Request for Biochemical Pesticide Data Requirements. 

Unpublished Study Prepared by GNL Consultation Services. 49 p.

47557101 Libman, G. (2008) Waiver Request for Biochemical Pesticide Data Requirements: 

Moss Buster. Unpublished study prepared by GNL Consultation Services. 44 p.

48093901 Libman, G. (2010) Waiver Request for Biochemical Pesticide Data Requirements. 

Unpublished Study Prepared by GNL Consultation Services. 49 p.

47557101 Libman, G. (2008) Waiver Request for Biochemical Pesticide Data Requirements: 

Moss Buster. Unpublished study prepared by GNL Consultation Services. 44 p.

48093901 Libman, G. (2010) Waiver Request for Biochemical Pesticide Data Requirements. 

Unpublished Study Prepared by GNL Consultation Services. 49 p.

47557101 Libman, G. (2008) Waiver Request for Biochemical Pesticide Data Requirements: 

Moss Buster. Unpublished study prepared by GNL Consultation Services. 44 p.

48093901 Libman, G. (2010) Waiver Request for Biochemical Pesticide Data Requirements. 

Unpublished Study Prepared by GNL Consultation Services. 49 p.

48351801 Libman, G. (2011) Waiver Request for Biochemical Pesticide Data Requirements 

NonTarget Insects: Moss Buster 84316-R. Unpublished study prepared by GNL 

Consultation Services. 5 p.

47276801 Libman, G. (2007) Waiver Request for Biochemical Pesticide Data Requirements: 

Moss Busters. Unpublished study prepared by GNL Consultation Services. 36 p.

47557101 Libman, G. (2008) Waiver Request for Biochemical Pesticide Data Requirements: 

Moss Buster. Unpublished study prepared by GNL Consultation Services. 44 p.

48093901 Libman, G. (2010) Waiver Request for Biochemical Pesticide Data Requirements. 

Unpublished Study Prepared by GNL Consultation Services. 49 p.

 47247400 Moss Buster LLC (2007) Submission of Toxicity Data in Support of the Application 

for Registration of Moss Buster. Transmittal of 1 Study.

47276800 Moss Buster LLC (2007) Submission of Toxicity Data in Support of the Application 

for Registration of Moss Buster. Transmittal of 1 Study.

47557100 Moss Buster, LLC (2008) Submission of Toxicity and Exposure and Risk Data in 

Support of the Application for Registration of Moss Buster. Transmittal of 1 Study.

48093900 Moss Buster, LLC (2010) Submission of Toxicity Data in Support of the 

Application for Registration of Moss Buster. Transmittal of 1 Study.

48322100 Moss Buster, LLC (2010) Submission of Product Chemistry Data in Support of the 
Oregano Oil (Origanum vulgar) Page 19 of 19

Biopesticides Registration Action Document

Application for Registration of Moss Buster. Transmittal of 3 Studies.

48339200 Moss Buster, LLC (2011) Submission of Product Chemistry Data in Support of the 

Application for Registration of Moss Buster. Transmittal of 1 Study.

48339201 Libman, G. (2010) Additional Product Chemistry Data: Moss Buster. Unpublished 

study prepared by GNL Consultation Services. 9 p.

48351800 Moss Busters LLC (2011) Submission of Toxicity Data in Support of the

Application for Registration of Moss Buster. Transmittal of 1 Study.

48363100 Moss Buster, LLC (2011) Submission of Toxicity Data in Support of the 

Application for Registration of Moss Buster. Transmittal of 1 Study.

48380801 Journal of Apicultural Research and Bee World 48(4): 263-269 (2009). Gashout 

 Hanan A. and Guzmán-Novoa Ernesto.